Before publication of the final rule, CMS had written(www.cms.gov) that the 30-day period for the TCM service began on the day of discharge and continued for the next 29 days – making the reported date of service the 30th day. However, in the final rule for 2016, CMS wrote:

"Regarding TCM services, we are adopting the commenters’ suggestions that the required date of service reported on the claim be the date of the face-to-face visit, and to allow (but not require) submission of the claim when the face-to-face visit is completed, consistent with current policy governing the reporting of global surgery and other bundles of services under the [physician fee schedule]."

CMS went on to state that it will revise the existing sub-regulatory guidance for TCM services accordingly. CMS provided no timetable for that revision. Most aspects of the final rule are not effective until Jan. 1, so you should probably not adjust your TCM billing practices before then. You should probably also confirm with your Medicare Administrative Contractor(www.cms.gov) that it is prepared to handle TCM claims as described by CMS before submitting such claims.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

The views expressed here do not necessarily reflect the opinions of FPM or the AAFP. Some payers may not agree with the advice given. This is not a substitute for current CPT and ICD-9 manuals and payer policies. All comments are moderated and will be removed if they violate our Terms of Use.

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